Melissa L. Land v. Washington County
Opinion
Melissa Land appeals the District Court’s 1 adverse grant of summary judgment in her action under the “association” provision of the Americans with Disabilities Act. See 42 U.S.C. § 12112(b)(4) (1994) (unlawful discrimination includes “excluding or otherwise denying equal jobs or benefits to a qualified individual because of the known disability of an individual with whom the qualified individual is known to have a relationship or association”). Having conducted a de novo review, see Mole v. Buckhorn Rubber Prods., Inc. 165 F.3d 1212, 1214 (8th Cir.) (standard of review), cert. denied, 528 U.S. 821, 120 S.Ct. 65, 145 L.Ed.2d 56 (1999), we affirm.
We agree with the District Court that Land failed to establish a prima facie case of association discrimination. See Hilburn v. Murata Elecs. N. Am., Inc., 181 F.3d 1220, 1230-31 (11th Cir. 1999) (listing elements of a prima facie case). We also conclude that the District Court did not abuse its discretion when it denied Land’s motions for discovery sanctions.
Accordingly, we affirm. See 8th Cir. R. 47B.
A true copy.
. The Honorable Michael J. Davis, United States District Judge for the District of Minnesota.
Reference
- Full Case Name
- Melissa L. LAND, Appellant, v. WASHINGTON COUNTY, Appellee
- Status
- Unpublished